Non-Solicitation Policy

1. POLICY STATEMENT

1.1 Our Non-Solicitation Policy outlines restrictions on distributing materials and/or soliciting funds, donations or signatures in activities or groups.
1.2 Solicitation is any form of requesting money, support or participation for products, groups, organisations or causes which are unrelated to our company.

2. WHO IS COVERED BY THIS POLICY?

2.1 This policy applies to all of our employees as well as subcontractors (including agency and self-employed Service Providers), consultants and employees of other organisations when working on our sites and premises, or the sites and premises of our clients.

3. RESTRICTIONS ON NON-EMPLOYEES

3.1 All forms of solicitation are strictly prohibited for contractors, service providers, suppliers, former employees, visitors and members of the public.

4. RESTRICTIONS ON EMPLOYEES

4.1 As an employee of H2O, you may solicit from your colleagues only when you want to:
4.1.1 Ask colleagues to help organise events for another employee (e.g. adoption/birth of a child, promotion, retiring.)
4.1.2 Seek support for a cause, charity or fundraising event sponsored, funded, organised or authorized by our company;
4.1.3 Invite colleagues to employee activities for an authorised non-business purpose (e.g. recreation, volunteering.);
4.1.4 Ask colleagues to participate in employment-related activities or groups protected by law (e.g. Trade Unions).
4.2 In all cases, we ask that you do not disturb, distract colleagues from their work. We also prohibit offensive solicitation or solicitation for personal profit, including:
4.2.1 Selling good for personal profit;
4.2.2 Requesting support or funding for political campaigns;
4.2.3 Unauthorised posting of non-work related material on company intranet or bulletin boards;
4.2.4 Solicitation or distribution of non-business literature towards customers, partners or vendors;
4.2.5 Proselytising others to groups or initiatives that violate policies concerning Equality, Diversity and Discrimination.
4.3 Employees have the legal right to refuse participation to any kind of activity or organisation.

5. BREACHES OF POLICY

5.1 Any employee, contractor, business, or its personnel who fails to comply with this policy shall, where applicable, be subject to disciplinary action as outlined in the employee contract, or any contract for services currently in force may be immediately terminated.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.